throbber
Case 1:12-cr-00185-LAP Document 9 Filed 05/02/12 Page 1 of 39
`Case 1:12—cr—00185-LAP Document9
`Filed 05/02/12 Page1 of 39
`
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
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`INDICTMENT
`
`s1 12 Cr. 185 (LAP)
`
`
`
`UNITED STATES OF AMERICA
`
`— v.
`
`—
`
`RYAN ACKROYD,
`
`a/k/a “kayla,"
`a/k/a “lol,”
`
`a/k/a “lolspoon,"
`JAKE DAVIS,
`
`a/k/a “topiary,”
`a/k/a “atopiary”
`DARREN MARTYN,
`
`a/k/a “pwnsauce,"
`a/k/a “raepsauce,”
`a/k/a “networkkitten,"
`DONNCHA O’CEARRBHAIL,
`
`a/k/a “palladium,” and
`JEREMY HAMMOND,
`
`a/k/a “Anarchaos,"
`a/k/a “sup_g,”
`a/k/a “burn,”
`
`a/k/a “yohoho,"
`a/k/a “POW,”
`a/k/a “tylerknowsthis,”
`a/k/a “crediblethreat,”
`
`a/k/a “ghost”
`a/k/a “anarchacker,”
`
`Defendants.
`
`COUNT ONE
`
`(CONSPIRACY TO COMMIT COMPUTER HACKING - INTERNET FEDS)
`
`The Grand Jury charges:
`
`THE DEFENDANTS
`
`1.
`
`At certain times relevant to this Indictment,
`
`RYAN ACKROYD, a/k/a “kayla," a/k/a “lol,” a/k/a “lolspoon," and
`
`

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`JAKE DAVIS, a/k/a “topiary,” a/k/a “atopiary," the defendants,
`
`were computer hackers who resided in the United Kingdom.
`
`2.
`
`The role of RYAN ACKROYD, a/k/a “kayla,” a/k/a
`
`“lol,” a/k/a “lolspoon," the defendant,
`
`included, among other
`
`things,
`
`identifying and exploiting vulnerabilities in victims’
`
`computer systems for the purpose of gaining unauthorized access
`
`to those systems for the groups charged in Counts One and Two of
`
`this Indictment.
`
`3.
`
`The role of JAKE DAVIS, a/k/a “topiary,” a/k/a
`
`“atopiary," the defendant,
`
`included, among other things, acting
`
`as a spokesman for the groups charged in Counts One and Two of
`
`this Indictment,
`
`for example by engaging in interviews with the
`
`media and publicizing those groups’ hacking activities; drafting
`
`press releases; and organizing and storing confidential
`
`information stolen in connection with the computer hacking
`
`described in Counts One and Two of this Indictment.
`
`4.
`
`At certain times relevant to this Indictment,
`
`DARREN MARTYN, a/k/a “pwnsauce,” a/k/a “raepsauce," a/k/a
`
`“networkkitten," and DONNCHA O’CEARRBHAIL, a/k/a “palladium,”
`
`the defendants, were computer hackers who resided in Ireland.
`
`5.
`
`At certain times relevant to this Indictment,
`
`JEREMY HAMMOND, a/k/a Anarchaos,” a/k/a “sup_g,” a/k/a “burn,”
`
`a/k/a “yohoho,” a/k/a “POW,” a/k/a “tylerknowsthis,” a/k/a
`
`“crediblethreat,” a/k/a “ghost,” a/k/a “anarchacker,” the
`
`

`
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`defendant, was a computer hacker who resided in Chicago,
`
`Illinois.
`
`BACKGROUND ON ANONYMOUS AND INTERNET FEDS
`
`6.
`
`Since at least in or about 2008, up through and
`
`including at least in or about March 2012,
`
`“Anonymous” has been
`
`a loose confederation of computer hackers and others sharing,
`
`among other things,
`
`common interests,
`
`common slogans, and common
`
`identifying symbols. During that time period, certain members
`
`of Anonymous have waged a deliberate campaign of online
`
`destruction,
`
`intimidation, and criminality, as part of which
`
`they have carried out cyber attacks against businesses and
`
`government entities in the United States and throughout the
`
`world.
`
`7.
`
`Between in or about December 2010 and in or about
`
`May 2011, one group of individuals affiliated with Anonymous who
`
`engaged in such criminal conduct was composed of elite computer
`
`hackers who collectively referred to themselves as “Internet
`
`Feds.” At various times relevant to this Indictment, members of
`
`Internet Feds carried out a series of cyber attacks against the
`
`websites and computer systems of certain business and government
`
`entities in the United States and around the world,
`
`including,
`
`among others,
`
`the following businesses and organizations:
`
`a.
`
`Fine Gael, a political party in Ireland,
`
`which maintained the website “www.finegael2011.com;”
`
`

`
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`b.
`
`HBGary,
`
`Inc. and its affiliate, HBGary
`
`Federal, LLC (collectively referred to herein as “HBGary”),
`
`computer security firms based in the United States which
`
`provided computer security software and services, among other
`
`things,
`
`to their clients, and which maintained the website
`
`“www.HBGaryFederal.com;” and
`
`c.
`
`Fox Broadcasting Company (“Fox”), a
`
`commercial broadcast television network in the United States,
`
`which maintained the website “www.fox.com.”
`
`8.
`
`These cyber attacks involved, among other things:
`
`(l) breaking into computer systems,
`
`deleting data, and stealing
`
`confidential information,
`
`including encrypted and unencrypted
`
`sensitive personal
`
`information for thousands of individual
`
`victims;
`
`(2) de—encrypting confidential information stolen from
`
`victims’
`
`computer systems,
`
`including encrypted passwords;
`
`(3)
`
`publicly
`
`disclosing that stolen confidential information on the
`
`Internet
`
`by dumping it on certain websites;
`
`(4) hijacking
`
`victims’
`
`email and Twitter accounts;
`
`(5)
`
`defacing victims’
`
`Internet
`
`websites; and/or (6) “doxing,” that is, publicly
`
`disclosing online a victim's personal identifying information,
`
`such as the victim's name, address, Social Security number,
`
`email account, and telephone number, with the object of, among
`
`other things,
`
`intimidating the victim and subjecting the victim
`
`to harassment.
`
`

`
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`9.
`
`At various times relevant to this Indictment, and
`
`as part of Anonymous, members of Internet Feds sought to
`
`publicize their Internet assaults and intimidate their victims
`
`by, among other things:
`
`(1) posting messages online in which
`
`they discussed their attacks and threatened additional attacks;
`
`(2) using particular logos and slogans when,
`
`for example,
`
`they
`
`posted messages online and defaced websites; and (3) discussing
`
`their attacks with members of the press.
`
`10. At various times relevant to this Indictment, and
`
`much like other members of Anonymous, members of Internet Feds,
`
`despite their efforts to publicize their illegal conduct,
`
`typically attempted to hide their true identities by, for
`
`example, using aliases when they communicated with the public or
`
`with each other.
`
`11. At various times relevant to this Indictment,
`
`members of Internet Feds, much like other members of Anonymous,
`
`communicated using, among other means, Internet Relay Chat
`
`(“IRC”) channels —- that is, real-time,
`
`text—based online
`
`forums.
`
`Some of these channels were open to the public.
`
`Others, particularly channels in which members of Anonymous and
`
`members of Internet Feds planned and organized criminal
`
`activity,
`
`including cyber attacks, were not.
`
`Instead,
`
`those
`
`channels were generally password—restricted and available by
`
`invitation only, usually to trusted individuals who had proven
`
`

`
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`themselves through past criminal hacking. Specifically, members
`
`of Internet Feds and their co-conspirators planned and
`
`coordinated their cyber attacks using password-restricted,
`
`invitation—only IRC channels such as “#InternetFeds,”
`
`“#Hackers,” and “#hq," among others.
`
`12. At various times relevant to this Indictment,
`
`the
`
`members of Internet Feds included, among others, RYAN ACKROYD,
`
`a/k/a “kayla,” a/k/a “lol," a/k/a “lolspoon," JAKE DAVIS, a/k/a
`
`“topiary,” a/k/a “atopiary,” DARREN MARTYN, a/k/a “pwnsauce,”
`
`a/k/a “raepsauce,” a/k/a “networkkitten,” and DONNCHA
`
`O’CEARRBHAIL, a/k/a “palladium,” the defendants, as well as
`
`other individuals,
`
`including, but not limited to,
`
`individuals
`
`who used the online aliases “SABU,”
`
`“TFLOW,” and “AVUNIT ”
`
`CYBER ATTACKS BY INTERNET FEDS
`
`13.
`
`From in or about December 2010, up to and
`
`including in or about May 2011, members of Internet Feds,
`
`including RYAN ACKROYD, a/k/a “kayla,” a/k/a “lol," a/k/a
`
`“lolspoon," JAKE DAVIS, a/k/a “topiary,” a/k/a “atopiary,”
`
`DARREN MARTYN, a/k/a “pwnsauce,” a/k/a “raepsauce,” a/k/a
`
`“networkkitten,” and DONNCHA O’CEARRBHAIL, a/k/a “palladium,”
`
`the defendants, and their co-conspirators,
`
`including, among
`
`others, SABU, TFLOW and AVUNIT,
`
`launched cyber attacks on, and
`
`gained unauthorized access to,
`
`the websites and computers
`
`systems of the following victims, among others:
`
`

`
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`Hack of Fine Gael
`
`a.
`
`In or about January 2011, MARTYN and
`
`O’CEARRBHAIL participated in a cyber attack on Fine Gael's
`
`website, www.finegael2011.com.
`
`Among other things, MARTYN and
`
`O’CEARRBHAIL accessed without authorization computer servers in
`
`Arizona used by Fine Gael to maintain its website, and uploaded
`
`code that defaced the website.
`
`Hack of HBGary
`
`b.
`
`In or about February 2011, ACKROYD, DAVIS,
`
`MARTYN, and their co—conspirators,
`
`including SABU, TFLOW and
`
`AVUNIT, participated in a cyber attack on the website and
`
`computer systems of HBGary.
`
`C.
`
`Among other things, ACKROYD, DAVIS, MARTYN,
`
`and their co-conspirators accessed without authorization
`
`computer servers in California and Colorado used by HBGary and
`
`stole confidential information from those servers,
`
`including
`
`approximately 60,000 emails from email accounts used by HBGary
`
`employees and a senior executive of HBGary Federal, LLC (the
`
`“HBGary Federal Executive"), which ACKROYD, DAVIS, and MARTYN,
`
`and their co-conspirators publicly disclosed via the
`
`www.thepiratebay.org website (an anonymous file sharing website
`
`that permits users to post stolen content), among other means.
`
`d.
`
`ACKROYD, DAVIS, MARTYN, and their Co-
`
`conspirators used information gained from those stolen emails to
`
`

`
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`access, without authorization, and steal the contents of an
`
`email account belonging to a senior executive of HBGary,
`
`Inc.
`
`(the “HBGary,
`
`Inc. Executive”); gain unauthorized access to the
`
`servers for the website www.rootkit.com, an online forum on
`
`computer hacking maintained by the HBGary,
`
`Inc. Executive, and
`
`steal confidential data,
`
`including usernames and encrypted
`
`passwords for approximately 80,000 user accounts; access without
`
`authorization and deface the Twitter account of the HBGary
`
`Federal Executive; and dox the HBGary Federal Executive by,
`
`among other things, posting his Social Security number and home
`
`address on his Twitter account without his authorization or
`
`approval.
`
`e.
`
`ACKROYD, DAVIS, MARTYN, and their co-
`
`conspirators de—encrypted tens of thousands of the encrypted
`
`www.rootkit.com users’ passwords that they had stolen, and
`
`publicly disclosed those de—encrypted passwords,
`
`the rootkit.com
`
`usernames they had stolen, and the contents of the email account
`
`belonging to the HBGary,
`
`Inc. Executive, by dumping them on
`
`certain Internet websites.
`
`Hack of Fox
`
`f.
`
`In or about April 2011, ACKROYD, DAVIS,
`
`MARTYN, O’CEARRBHAIL, and their co—conspirators,
`
`including SABU,
`
`TFLOW and AVUNIT, participated in a cyber attack on the website
`
`and computer systems of Fox.
`
`

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`g.
`
`Among other things, ACKROYD, DAVIS, MARTYN,
`
`O’CEARRBHAIL, and their co—conspirators accessed without
`
`authorization computer servers in California used by Fox and
`
`stole and publicly disclosed confidential information,
`
`including
`
`a database of the names, dates of birth,
`
`telephone numbers,
`
`email addresses, and residences, among other information, for
`
`more than 70,000 potential contestants on “X—Factor,” a Fox
`
`television show.
`
`STATUTORY ALLEGATIONS
`
`14.
`
`From at least in or about December 2010, up to
`
`and including in or about May 2011,
`
`in the Southern District of
`
`New York and elsewhere, RYAN ACKROYD, a/k/a “kayla,” a/k/a
`
`“lol,” a/k/a “lolspoon,” JAKE DAVIS, a/k/a “topiary,” a/k/a
`
`“atopiary," DARREN MARTYN, a/k/a “pwnsauce,” a/k/a “raepsauce,”
`
`a/k/a “networkkitten," and DONNCHA O’CEARRBHAIL, a/k/a
`
`“palladium,” the defendants, and others known and unknown,
`
`willfully and knowingly, combined, conspired, confederated, and
`
`agreed together and with each other to engage in computer
`
`hacking,
`
`in violation of Title 18, United States Code, Section
`
`1030(a)(5)(A).
`
`15.
`
`It was a part and an object of the conspiracy
`
`that RYAN ACKROYD, a/k/a “kayla,” a/k/a “lol,” a/k/a “lolspoon,”
`
`JAKE DAVIS, a/k/a “topiary,” a/k/a “atopiary," DARREN MARTYN,
`
`a/k/a “pwnsauce,” a/k/a “raepsauce,” a/k/a “networkkitten," and
`
`

`
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`DONNCHA O'CEARRBHAIL, a/k/a “palladium,” the defendants, and
`
`others known and unknown, willfully and knowingly would and did
`
`cause the transmission of a program,
`
`information, code and
`
`command, and, as a result of such conduct, would and did
`
`intentionally cause damage without authorization,
`
`to a protected
`
`computer, which would and did cause a loss (including loss
`
`resulting from a related Course of conduct affecting one and
`
`more other protected computers) aggregating to at least $5,000
`
`to one and more persons during any one year period,
`
`in violation
`
`of Title 18, United States Code, Sections 1030(a)(5)(A),
`
`1030(c) (4) (B) (i) and (c) (4) (A) (i) (I).
`
`OVERT ACTS
`
`16.
`
`In furtherance of the conspiracy and to effect
`
`the illegal object thereof,
`
`the following overt acts, among
`
`others, were committed in the Southern District of New York and
`
`elsewhere:
`
`a.
`
`On or about January 9, 2011, DONNCHA
`
`O'CEARRBHAIL, a/k/a “palladium,” the defendant, sent an
`
`electronic communication to DARREN MARTYN, a/k/a “pwnsauce,”
`
`a/k/a “raepsauce,” a/k/a “networkkitten,” the defendant,
`
`containing computer code to be used to deface the
`
`www finegael20l1.com website.
`
`b.
`
`In or about February 2011, SABU used a
`
`computer located in New York, New York to access without
`
`10
`
`

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`authorization computer servers used by HBGary and steal tens of
`
`thousands of emails belonging to employees of HBGary and the
`
`HBGary Federal Executive.
`
`c.
`
`In or about February 2011,
`
`JAKE DAVIS, a/k/a
`
`“topiary,” a/k/a “atopiary,” the defendant, accessed without
`
`authorization the Twitter account of the HBGary Federal
`
`Executive and posted one or more fraudulent tweets.
`
`d.
`
`In or about February 2011, RYAN ACKROYD,
`
`a/k/a “kayla,” a/k/a “lol," a/k/a “lolspoon," the defendant,
`
`accessed without authorization an email account belonging to the
`
`HBGary,
`
`Inc. Executive and sent one or more fraudulent emails
`
`from that account to an administrator for the www.rootkit.com
`
`website requesting administrative access to that website.
`
`e.
`
`On or about February 7, 2011, TFLOW uploaded
`
`links to tens of thousands of stolen emails belonging to
`
`employees of HBGary and the HBGary Federal Executive as well as
`
`a copy of certain text that had been used to deface the
`
`www.HBGaryFederal com website,
`
`to an account on the website
`
`www.thepiratebay.org in the name “HBGary leaked emails."
`
`f.
`
`On or about February 8, 2011, DAVIS, using
`
`the IRC channel #hq, discussed how Twitter had locked the
`
`Twitter account of the HBGary Federal Executive and stated,
`
`“That works in our favour. His Twitter still has all our
`
`tweets.
`
`Including his SSN.”
`
`ll
`
`

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`g.
`
`On or about February 9, 2011, ACKROYD, using
`
`the IRC channel #hq, asked TFLOW whether he had received a copy
`
`of emails belonging to the HBGary,
`
`Inc. Executive,
`
`to which
`
`TFLOW responded affirmatively and stated that he would add them
`
`to an “online viewer.”
`
`h.
`
`On or about February 12, 2011, SABU, using
`
`the IRC channel #hq, stated that he had deleted data on a server
`
`used by HBGary.
`
`i.
`
`On or about February 13, 2011, DAVIS, using
`
`the IRC channel #hq,
`
`told AVUNIT “I'm happy to talk to press on
`
`IRC/Skype, have done [so]
`
`for months,” and told TFLOW that he
`
`had “talked to maybe 150 journalists."
`
`j.
`
`In or about May 2011, SABU used a computer
`
`in New York, New York to access without authorization a computer
`
`server used by Fox and download a database containing personal
`
`information relating to potential contestants on the X—Factor
`
`television show.
`
`(Title 18, United States Code, Section 1030(b).)
`
`COUNT TWO
`
`(CONSPIRACY TO COMMIT COMPUTER HACKING — LULZSEC)
`
`The Grand Jury further charges:
`
`17.
`
`The allegations in paragraphs 1 through 6 of this
`
`Indictment are repeated and realleged as though fully set forth
`
`herein.
`
`l2
`
`

`
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`BACKGROUND ON LULZSEC
`
`18.
`
`In or about May 2011,
`
`following the publicity
`
`that they had generated as a result of their hacking of Fine
`
`Gael and HBGary, among other victims, members of Internet Feds,
`
`including RYAN ACKROYD, a/k/a “kayla,” a/k/a “lol,” a/k/a
`
`“lolspoon," JAKE DAVIS, a/k/a “topiary,” a/k/a “atopiary,” and
`
`DARREN MARTYN, a/k/a “pwnsauce,” a/k/a “raepsauce,” a/k/a
`
`“networkkitten,” the defendants, as well as SABU, TFLOW, and
`
`AVUNIT,
`
`formed and became the principal members of a new hacking
`
`group, “Lulz Security” or “Lulzsec.” Other co—conspirators,
`
`including JEREMY HAMMOND, a/k/a “Anarchaos,” a/k/a “sup_g,”
`
`a/k/a “burn,” a/k/a “yohoho,” a/k/a “POW,” a/k/a
`
`“tylerknowsthis,” a/k/a “crediblethreat," a/k/a “ghost,” a/k/a
`
`“anarchacker," the defendant, also participated in some of
`
`LulzSec’s hacking activities.
`
`19. Like Internet Feds, Lulzsec undertook a campaign
`
`of malicious cyber assaults on the websites and computer systems
`
`of various business and government entities in the United States
`
`and throughout
`
`the world. Although the members of Lulzsec and
`
`their co—conspirators claimed to have engaged in these attacks
`
`for humorous purposes (“lulz” is Internet slang which can be
`
`interpreted as “laughs,” “humor,” or “amusement”), LulzSec’s
`
`criminal acts included, among other things,
`
`the theft of
`
`confidential information,
`
`including sensitive personal
`
`13
`
`

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`information for thousands of individuals,
`
`from their victims’
`
`computer systems;
`
`the public disclosure of that confidential
`
`information on the Internet;
`
`the defacement of Internet
`
`websites; and overwhelming victims’ computers with bogus
`
`requests for information (known as “denial of service" or “Dos”
`
`attacks).
`
`20. Also like Internet Feds, Lulzsec sought to gain
`
`notoriety for their hacks by varied and repeated efforts to
`
`broadcast their acts of online destruction and criminality. As
`
`a means of publicizing their cyber assaults, members of Lulzsec
`
`and their co-conspirators maintained a website,
`
`“www.LulzSecurity.com;" an account in the name “Lulzsec” at
`
`www.thepiratebay.org; and a Twitter account, “@LulzSec;" all of
`
`which they used to, among other things, announce their hacks and
`
`issue written “press releases” about
`
`them; mock their victims;
`
`solicit donations; and publicly disclose confidential
`
`information they had stolen through their cyber attacks.
`
`21. Similar to Internet Feds, as a means of
`
`publicizing their online assaults, as well as intimidating their
`
`victims, members of Lulzsec and their co-conspirators used
`
`particular logos and slogans in, for example,
`
`their “press
`
`releases," their website defacements, and on the
`
`www.LulzSecurity.com website and the @LulzSec Twitter account.
`
`14
`
`

`
`Case 1:12-cr-00185-LAP Document 9 Filed 05/02/12 Page 15 of 39
`Case 1:12—cr—00185—LAP Document 9
`Filed 05/02/12 Page 15 of 39
`
`22. Despite going to great lengths to seek attention
`
`for their illegal conduct,
`
`the members of Lulzsec and their co-
`
`conspirators —-
`
`like Internet Feds —— attempted to hide their
`
`true identities.
`
`Among other things,
`
`they referred to
`
`themselves by aliases, attempted to promote false personas, and
`
`used technical means,
`
`including proxy servers,
`
`in an effort to
`
`conceal
`
`themselves online.
`
`23. At various times relevant to this Indictment,
`
`members of Lulzsec,
`
`including RYAN ACKROYD, a/k/a “kayla,” a/k/a
`
`“lol,” a/k/a “lolspoon,” JAKE DAVIS, a/k/a “topiary,” a/k/a
`
`“atopiary,” and DARREN MARTYN, a/k/a “pwnsauce,” a/k/a,
`
`“raepsauce,” a/k/a “networkkitten,” the defendants, as well as
`
`SABU, TFLOW, and AVUNIT, and their co—conspirators,
`
`including,
`
`at times,
`
`JEREMY HAMMOND, a/k/a “Anarchaos," a/k/a “sup_g,”
`
`a/k/a “burn,” a/k/a “yohoho," a/k/a “POW,” a/k/a
`
`“tylerknowsthis,” a/k/a “crediblethreat,” a/k/a “ghost,” a/k/a
`
`“anarchacker," the defendant,
`
`launched cyber attacks on the
`
`websites and computer systems of the following victims, among
`
`others:
`
`a.
`
`Sony Pictures Entertainment
`
`(“Sony
`
`Pictures”), a division of Sony, a global electronics and media
`
`company, which produced and distributed television shows and
`
`movies and maintained the website “www.sonypictures.com;”
`
`15
`
`

`
`Case 1:12-cr-00185-LAP Document 9 Filed 05/02/12 Page 16 of 39
`Case 1:12—cr—00185—LAP Document 9
`Filed 05/02/12 Page 16 of 39
`
`b.
`
`The Public Broadcasting Service (“PBS”), a
`
`non-profit public television broadcasting service in the United
`
`States, which maintained the website “www.pbs.org;”
`
`C.
`
`The Atlanta, Georgia chapter of the
`
`Infragard Members Alliance (“Infragard—Atlanta"), an information
`
`sharing partnership between the Federal Bureau of Investigation
`
`(“FBI”) and private industry concerned with protecting critical
`
`infrastructure in the United States, which maintained the
`
`website “www.infraguardatlanta.org;”
`
`d.
`
`Bethesda Softworks, a video game company
`
`based in Maryland, which owned the videogame “Brink” and
`
`maintained the website www.brinkthegame.com.; and
`
`e.
`
`The Arizona Department of Public Safety (the
`
`“Arizona DPS”), a state law enforcement agency in Arizona, which
`
`maintained the website “www.azdps.gov.”
`
`24. At various times relevant to this Indictment,
`
`in
`
`addition to identifying and exploiting vulnerabilities in their
`
`victims’ computer systems on their own,
`
`the members of Lulzsec
`
`received from other computer hackers information regarding
`
`vulnerabilities in the computer systems of a variety of business
`
`and government entities. Lulzsec members then used this
`
`information to launch cyber attacks on those entities or stored
`
`this information in anticipation of future attacks.
`
`16
`
`

`
`Case 1:12-cr-00185-LAP Document 9 Filed 05/02/12 Page 17 of 39
`Case 1:12—cr—00185-LAP Document 9
`Filed 05/02/12 Page 17 of 39
`
`25. At various times relevant to this Indictment,
`
`members of Lulzsec and their co-conspirators communicated with
`
`each other and planned and coordinated their cyber attacks using
`
`password-restricted,
`
`invitation-only IRC channels,
`
`including,
`
`among others, “#upperdeck” and “#hq".
`
`CYBER ATTACKS BY LULZSEC
`
`26.
`
`From in or about May 2011, up to and including at
`
`least in or about June 2011, members of Lulzsec,
`
`including RYAN
`
`ACKROYD, a/k/a “kayla,” a/k/a “lol,” a/k/a “lolspoon,” JAKE
`
`DAVIS, a/k/a “topiary,” a/k/a “atopiary,” DARREN MARTYN, a/k/a
`
`“pwnsauce,” a/k/a “raepsauce,” a/k/a “networkkitten," the
`
`defendants, as well as SABU, TFLOW, and AVUNIT, and their co-
`
`conspirators,
`
`including, among others,
`
`JEREMY HAMMOND, a/k/a
`
`“Anarchaos,” a/k/a “sup_g,” a/k/a “burn,” a/k/a “yohoho," a/k/a
`
`“POW,” a/k/a “tylerknowsthis,” a/k/a “crediblethreat,” a/k/a
`
`“ghost,” a/k/a “anarchacker," the defendant,
`
`launched cyber
`
`attacks on, and gained unauthorized access to,
`
`the websites and
`
`computers systems of the following victims, among others:
`
`Hack of PBS
`
`a.
`
`In or about May 2011, ACKROYD, DAVIS,
`
`MARTYN, and their co-conspirators,
`
`including SABU, TFLOW and
`
`AVUNIT,
`
`in retaliation for what they perceived to be unfavorable
`
`news coverage in an episode of the PBS news program Frontline,
`
`17
`
`

`
`Case 1:12-cr-00185-LAP Document 9 Filed 05/02/12 Page 18 of 39
`Case 1:12—cr—00185—LAP Document 9
`Filed 05/02/12 Page 18 of 39
`
`undertook a cyber attack on the website and computer systems of
`
`PBS.
`
`b.
`
`ACKROYD, DAVIS, MARTYN, and their co-
`
`conspirators, accessed without authorization computer servers in
`
`Virginia used by PBS, stole confidential information from those
`
`servers,
`
`including, among other things, databases containing
`
`names, email addresses, usernames and passwords of more than
`
`approximately 2,000 PBS employees and other individuals and
`
`entities associated with PBS; publicly disclosed that
`
`information on certain websites,
`
`including the
`
`www.LulzSecurity.com website; and defaced the PBS website,
`
`including by inserting a bogus news article.
`
`Hack of Sony Pictures
`
`c.
`
`In or about May 2011, ACKROYD, DAVIS, and
`
`their co—conspirators,
`
`including SABU, TFLOW and AVUNIT,
`
`participated in a cyber attack on computer systems used by Sony
`
`Pictures. This attack included accessing without authorization
`
`Sony Pictures’ computer servers in California, and stealing and
`
`publicly disclosing on certain websites,
`
`including the
`
`www.LulzSecurity.com website, confidential information for at
`
`least approximately 100,000 users of the www.sonypictures.com
`
`website,
`
`including the users’ passwords, email addresses, home
`
`addresses, and dates of birth.
`
`18
`
`

`
`Case 1:12-cr-00185-LAP Document 9 Filed 05/02/12 Page 19 of 39
`Case 1:12—cr—00185—LAP Document 9
`Filed 05/02/12 Page 19 of 39
`
`Hack of Infragard—Atlanta
`
`d.
`
`In or about June 2011, ACKROYD, DAVIS,
`
`MARTYN, and their co-conspirators,
`
`including SABU, TFLOW and
`
`AVUNIT,
`
`launched cyber attacks on the website and computer
`
`systems of Infragard—Atlanta.
`
`These attacks included stealing
`
`the login credentials, encrypted passwords, and other
`
`confidential information for approximately 180 users of the
`
`Infragard-Atlanta website, www.atlantainfraguard.org; defacing
`
`that website; de—encrypting the stolen passwords; and publicly
`
`disclosing the stolen confidential user information,
`
`including
`
`the de—encrypted passwords, on certain websites,
`
`including the
`
`www.LulzSecurity.com website.
`
`Hack of Bethesda Softworks
`
`e.
`
`In or about June 2011, ACKROYD, DAVIS,
`
`MARTYN, and their co-conspirators,
`
`including TFLOW,
`
`participated in a cyber attack on the computer systems used by
`
`Bethesda Softworks, stealing confidential information,
`
`including
`
`authorization keys, as well as usernames, passwords, and email
`
`accounts for approximately 200,000 users of Bethesda Softworks’
`
`website, “www.brinkthegame.com.”
`
`ACKROYD, DAVIS, MARTIN, and
`
`their co-conspirators, publicly disclosed some of that stolen
`
`data on certain websites,
`
`including the www.LulzSecurity.com
`
`website.
`
`19
`
`

`
`Case 1:12-cr-00185-LAP Document 9 Filed 05/02/12 Page 20 of 39
`Case 1:12—cr—00185—LAP Document 9
`Filed 05/02/12 Page 20 of 39
`
`Hack of the Arizona DPS
`
`f.
`
`In or about June 2011, DAVIS, HAMMOND, and
`
`their co—conspirators,
`
`including TFLOW, participated in a cyber
`
`attack on the computer systems used by the Arizona DPS. Among
`
`other things,
`
`they accessed without authorization the Arizona
`
`DPS’s computer servers in Arizona, and stole and publicly
`
`disclosed on certain websites,
`
`including the website
`
`www Lulzssecurity com, confidential information such as law
`
`enforcement sensitive documents and personal
`
`information for
`
`Arizona law enforcement personnel and their family members,
`
`including names, email accounts and passwords, home addresses,
`
`and home telephone and cell phone numbers.
`
`STATUTORY ALLEGATIONS
`
`27.
`
`From at least in or about May 2011, up to and
`
`including at least in or about June 2011,
`
`in the Southern
`
`District of New York and elsewhere, RYAN ACKROYD, a/k/a “kayla,”
`
`a/k/a “lol," a/k/a “lolspoon,” JAKE DAVIS, a/k/a “topiary,”
`
`a/k/a “atopiary," DARREN MARTYN, a/k/a “pwnsauce,” a/k/a
`
`“raepsauce," a/k/a “networkkitten,” and JEREMY HAMMOND, a/k/a
`
`“Anarchaos,” a/k/a “sup_g,” a/k/a “burn,” a/k/a “yohoho,” a/k/a
`
`“POW,” a/k/a “tylerknowsthis,” a/k/a “crediblethreat,” a/k/a
`
`“ghost,” a/k/a “anarchacker,” the defendants, and others known
`
`and unknown, willfully and knowingly, combined, conspired,
`
`confederated, and agreed together and with each other to engage
`
`20
`
`

`
`Case 1:12-cr-00185-LAP Document 9 Filed 05/02/12 Page 21 of 39
`Case 1:12—cr—00185-LAP Document9
`Filed 05/02/12 Page 21 of 39
`
`in computer hacking,
`
`in violation of Title 18, United States
`
`Code, Section lO30(a)(5)(A).
`
`28.
`
`It was a part and an object of the conspiracy
`
`that RYAN ACKROYD, a/k/a “kayla,” a/k/a “lol,” a/k/a “lolspoon,"
`
`JAKE DAVIS, a/k/a “topiary,” a/k/a “atopiary,” DARREN MARTYN,
`
`a/k/a “pwnsauce,” a/k/a “raepsauce,” a/k/a “networkkitten,” and
`
`JEREMY HAMMOND, a/k/a “Anarchaos," a/k/a “sup_g," a/k/a “burn,”
`
`a/k/a “yohoho," a/k/a “POW,” a/k/a “tylerknowsthis,” a/k/a
`
`“crediblethreat,” a/k/a “ghost,” a/k/a “anarchacker,” the
`
`defendants, and others known and unknown, willfully and
`
`knowingly would and did cause the transmission of a program,
`
`information, code and command, and, as a result of such conduct,
`
`would and did intentionally cause damage without authorization,
`
`to a protected computer, which would and did cause a loss
`
`(including loss resulting from a related course of conduct
`
`affecting one and more other protected computers) aggregating to
`
`at least $5,000 to one and more persons during any one year
`
`period,
`
`in violation of Title 18, United States Code, Sections
`
`lO30(a)(5)(A),
`
`l030(C)(4)(B)(i) and (C)(4)(A)(i)(I).
`
`OVERT ACTS
`
`29.
`
`In furtherance of the conspiracy and to effect
`
`the illegal object thereof,
`
`the following overt acts, among
`
`others, were committed in the Southern District of New York and
`
`elsewhere:
`
`21
`
`

`
`Case 1:12-cr-00185-LAP Document 9 Filed 05/02/12 Page 22 of 39
`Case 1:12—cr—00185-LAP Document 9
`Filed 05/02/12 Page 22 of 39
`
`a.
`
`On or about May 6, 2011,
`
`JAKE DAVIS, a/k/a
`
`“topiary,” a/k/a “atopiary," the defendant, established a
`
`Twitter account in the name “@LulzSec.”
`
`b.
`
`In or about May 2011, SABU used a computer
`
`located in New York, New York,
`
`to gain unauthorized access to
`
`computer systems used by PBS and install one or more
`
`surreptitious means
`
`(“backdoors") by which SABU and others could
`
`secretly re—access those systems without authorization.
`
`c.
`
`In or about May 2011, DAVIS wrote a bogus
`
`news article, which was used to deface the www.pbs.org website.
`
`d.
`
`In or about May 2011, RYAN ACKROYD, a/k/a
`
`“kayla,” a/k/a “lol," a/k/a “lolspoon,” the defendant, and SABU
`
`accessed without authorization computer servers used by PBS and
`
`downloaded confidential information.
`
`e.
`
`In or about May 2011, SABU used a computer
`
`located in New York, New York,
`
`to gain unauthorized access to
`
`servers used by Sony Pictures.
`
`f.
`
`In or about June 2011, SABU used a computer
`
`located in New York, New York to gain unauthorized access to,
`
`and install one or more backdoors in, computer systems used by
`
`Infragard—Atlanta.
`
`g.
`
`In or about June 2011, ACKROYD accessed
`
`without authorization servers used by Infraguard—Atlanta and
`
`downloaded confidential information.
`
`22
`
`

`
`Case 1:12-cr-00185-LAP Document 9 Filed 05/02/12 Page 23 of 39
`Case 1:12—cr—00185—LAP Document 9
`Filed 05/02/12 Page 23 of 39
`
`h.
`
`In or about June 2011, a co—conspirator not
`
`named as a defendant herein provided information concerning a
`
`vulnerability in computer systems used by Bethesda Softworks to
`
`ACKROYD and other members of Lulzsec.
`
`i.
`
`On or about June 12, 2011, ACKROYD used the
`
`foregoing vulnerability to gain unauthorized access to computer
`
`systems used by Bethesda Softworks,
`
`install one or more
`
`backdoors, which he provided to other members of LulzSec, and
`
`download confidential information.
`
`j.
`
`In or about June 2011, DAVIS used a backdoor
`
`provided by ACKROYD to access without authorization computer
`
`systems used by Bethesda Softworks and download confidential
`
`information, which DAVIS then organized.
`
`k.
`
`On or about June 12, 2011, DARREN MARTYN,
`
`a/k/a “pwnsauce," a/k/a “raepsauce,” a/k/a “networkkitten," the
`
`defendant, posted the following message in the IRC channel
`
`#upperdeck:
`
`“Ok, who are we raping, brink?” to which ACKROYD
`
`responded affirmatively.
`
`1.
`
`On or about June 12, 2011, DAVIS posted the
`
`following message in the IRC channel #upperdeck: “so everyon

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